Regulatory Alerts2016-01-22
Primary Financial Company, LLC No Action Letter
The Pennsylvania Department of Banking and Securities issued this letter to confirm that federally-insured certificates of deposit are not considered securities under the Pennsylvania Securities Act of 1972. Relying on federal precedents and the identical insurance protections provided by the FDIC and NCUSIF, the Department determined that Primary Financial Company's activities do not trigger registration requirements. Consequently, Primary and its co-agents are exempt from registering as broker-dealers in Pennsylvania for these specific transactions.
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